ML20195B924

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Motion for Summary Disposition of New England Coalition on Nuclear Pollution Contention NHLP-3 & Sapl Contention 17, Based on Gj Catapano Affidavit & Encl Statement of Facts Re Reliability of Plume Emergency Planning Zone Communications
ML20195B924
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 05/20/1986
From: Dignan T
PUBLIC SERVICE CO. OF NEW HAMPSHIRE, ROPES & GRAY
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20195B803 List:
References
RTR-NUREG-0654, RTR-NUREG-654 OL, NUDOCS 8605290588
Download: ML20195B924 (7)
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Dated: May 20, 1986 ggLNLt UNITED STATES OF AMERICA ' y> .,

NUCLEAR REGULATORY COMMISSION (=

before the 1 Nh gosB6"09 ir ,

\7 __,.7,, yc i ATOMIC SAFETY AND LICENSING BOARD -; .

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Ini-the Matter'of )

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PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL

) Off-site Emergency (Seabrook Station, Units 1 and 2 ) Planning Issues.

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APPLICANTS' MOTION-FOR

SUMMARY

DISPOSITION OF NECNP CONTENTION NHLP-3 AND SAPL CONTENTION 17 ,

Pursuant to 10 CFR $ 2.749, on the basis of the

' Affidavit of Gary J. Catapano re NECNP Contention NHLP-3 and SAPL Contention 17 ("Catapano Affidavit") and the statement e

of. undisputed facts attached hereto and for the reasons set forth below, the Applicants move the Board to enter an order summarily disposing of NECNP Contention NHLP-3 and SAPL-17 in Applicants' favor.

REASONS FOR GRANTING THE MOTION .

NECNP Contention NHLP-3, as admitted reads as follows:

8605290588 860520 PDR O ADOCK 05000443

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1 "The local emergency response plans for ths New Hampshire towns surrounding Seabro.ok do not adequately provide for

' notification, by the licensee, of State and local response organizations and for notification of emergency response personnel by all organizations,' as required by 10 CFR.9 50.47(b)(5), in the following respects:

a. Provision for notification and communication by Public Service Co.

with the town emergency response organizations is inadequate in that it depends upon notification through the county dispatch and does not assure that the contact person will be available or can be reached in the event of a nuclear emergency."

SAPL Contention No. 17 reads as follows:

"The New Hampshire State and local plans fail to make adequate provisions for prompt communications among principal response organizations to emergency personnel and to the public.

Therefore, the plans do not meet the requirements of 10 CFR $

50.47(b)(1), S 50.47(b)(5) and (b)(6) and NUREG-0654 Planning Standard F."

The Catapano Affidavit makes clear that there exists a highly reliable communications network in the PEPZ. The Rockingham County Dispatch Center (" RCD") obviously is well equipped to perform its tasks.

Insofar as the NECNP contention alleges that plans "[do]

not assure that the contact person will be available or can be reached," we note that no plan can assure that. In the world at large people must be relied upon to do their duty.

Certainly the equipment is sufficient to make contact

Y through multiple channels. No plan can " assure" that a given official will be where he or she is supposed to ne at any given time. The only way one could " assure" such a

thing is to handcuff the person to a desk.

What is clear is that appropriate officials have been

designated and more than adequate radio and telephone i

equipment has been, or will be, supplied to perform the task. No more is required.

By their attorneys, Thomas Cl. dignan, Jr.

Robert K. Gad III Ropes & Gray 225 Franklin Street

, Boston, Massachusetts 02110 l (617) 423-6100 6

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r STATEMENT OF FACTS NOT IN DISPUTE

1. As part of an EPZ wide effort to upgrade the existing communications systems discussions were held with local and state public safety officials. Based upon an evaluation of the existing communications equipment, input based upon experiences of these public safety officials during past public safety emergencies, consideration for ,

technical engineering parameters and design objectives and an analysis of the communications requirements of the RERP a reconfiguration of many of these systems was recommended.

2. A complete complement of radio communications  :

equipment was purchased for all EPZ police departments to allow sufficient quantities of portables and pagers and mobile units to insure adequate communications resources existed to. staff all traffic control ~ posts and have portables available.for routine police activities that may occur at the same time an incident occurs at Seabrook Station. Additionally base stations and other types of communications equipment was also purchased to facilitate RERP communications.

3. New mobile units, portables, and pagers were also i

purchased for the Fire Department. All of the equipment purchased is wide band multifrequency, capable of allowing communications to occur on numerous frequencies. In most i 7

6 communities within the EPZ new dual address pagers were supplied for the police and fire departments and for use by the key municipal officials as outlined by the RERP.

4. A complete communications package was also purchased for each local EOC. Included in this package was a NHCDA command and control radio and a (2) meter Races radio which serves as a backup system for command and control. New high power multifrequency scanning base stations were also purchased to allow communications with surrounding communities emergency response organizations and other agencies that might be sent in to assist. New multiline telephone systems have also been purchased and additional phone lines will be added to the EOCs to provide adequate telephone communications. Sufficient portables, pagers and mobiles have been purchased to allow the fire and police departments to conduct their routine public safety activities at the same time that communictions resources are being utilized for communicating information related to the RERP.
5. The local communications network is engineered to allow the EOC in each local community to coordinate and control the town's emergency response activities and communicate directly with RCD, the State, surrounding EPZ communities, host communities and other agencies that may be sent in to assist (Example: In the case of the beach ,

communities this would include the USCG).

S.

i 4 6. In the case of the towns.of Hampton and Seabrook i

specialized communications systems were designed. In the case of Hampton the sophistication and reliability of their newly installed emergency communications network is without equal anywhere in the Northeast.

7. At Rockingham County Dispatch Center a number of improvements have been made to allow for the additional

. communications associated with Seabrook Station and the RERP. Special paging encoders have been installed to facilitate the required paging notifications and to simplify the actions required by the dispatcher to achieve them. The 2 . transceiver primarily utilized for the paging notifications 1

is being replaced with a new continuous duty rated, high

- power. station. A new phone system has been installed at the dispatch center along with specialized emergency line and 1

call logging recorders. An additional communications 4

console and fire dispatch area have been added to allow

- greater flexibility for dispatch operations and to accommodate the status display board and siren activation equipment.
8. The signal strength from.the transmitter sites

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utilized by Rockingham County Dispatch to communicate with all EPZ communities is more than adequate for all paging and mobile communications. Numerous channels exist for RERP communications to occur on, providing redundancy should a

channel become unusable for any reason.

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r i- 9. Once the State IFO at Newington becomes operational the primary responsibility for providing RERP notifications and RERP communications to the local EPZ communities shifts to the IFO. The IFO is equipped with a sophisticated ,

communications network that will allow representatives present at the IFO coordinating response activities the ability to communicate directly with field personnel.

Should the command and control radio system encounter high traffic the IFO can communicate directly with the local communities on either their own fire, police and highway department local frequencies. Additional radio communications capabilities exist to allow the IFO to communicate directly with the state Civil Defense and state police agencies in Maine and Masschusetts, all EMS vehicles, USCG, and the New Hampshire Department of Parks and Recreation. As part of the evaluation of the New Hampshire emergency response organizations communications capabilities improvements were also made to the state police

-communications systems for both Massachusetts and New Hampshire.

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